Capital Warehouse Co. v. Commissioner
United States Tax Court
Respondent's determination that a public warehouse company keeping its books and filing its returns on the accrual basis could not, during the first two years of its existence, exclude from its income that portion thereof which the company set aside in a reserve account as its contractual liability to remove goods from its warehouse at the end of the storage period, held to be justified by section 41, I. R. C.
1Opinion of the Court
OPINION.
Harlan, Judge:
The sole issue for decision concerns the correctness of the respondent’s determination that the petitioner may not exclude from its income for the taxable years the amounts transferred to its “Reserve for Handling Out” account.
Section 41 of the Internal Revenue Code provides that net income shall be computed upon the basis of the taxpayer’s annual accounting period in accordance with the method of accounting regularly employed in keeping the books of such taxpayer; but if no such method of accounting has been so employed, or if the method does not clearly reflect the…
2Cases cited8 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930
- Williamsport Wire Rope Co. v. United StatesSupreme Court of the United States · 1928
- Your Health Club, Inc. v. CommissionerUnited States Tax Court · 1944
3 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951
- Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
- Veenstra & De Haan Coal Co. v. CommissionerUnited States Tax Court · 1948
- Beacon Publishing Co. v. CommissionerUnited States Tax Court · 1954
- Capital Warehouse Co. v. Commissioner of Internal Rev.Court of Appeals for the Eighth Circuit · 1948
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